Royal Dutch
Shell Plc .com:
Statement by Bill Campbell: The Shell Brent Scandal: His detailed response to
recent comments by Shell: Published 8 July 2006

W.M Campbell -
B.Sc. MIEE C, Eng.

In 1999, SIEP Lead Auditor for PSMR review

Right of Reply

Who is this note intended for?

Directed to
Chairman, Executive and Non Executive Directors of Royal Dutch Shell

Copied to CEO of
HSE UK, my MSP who is helping me with my discussions with the Solicitor General
for Scotland, OILC, and selected media links

What is this Note about?

In response to
the article in Upstream newspaper Shell issued a note worldwide within its
Exploration and Production (EP) business sector to its employees.

While it is
disappointing that I did not get to read the Upstream article in advance, and
would have not written it in parts as published in the manner chosen, and not
mentioned WoodGroup whose people were in essence acting under instruction, and
not used names but job titles, nevertheless I stand by every word printed. I
also wanted both BBC and Upstream to concentrate on Shell and others, but also
on my general concern about the weakness apparent in the current offshore safety
regime.

Your statement
released to EP staff stated that the article made

·a
number of very serious allegations against Shell in its operations of the Brent
Field and some very personal and completely unjustified attack on current
and former members of staff. Shell strongly refutes these allegations.

Newspapers have
also carried strong rebuttals for example

·
The allegations regarding operating with high-risk levels are untrue, and
we absolutely refute this. Safety is our first priority

·
The recent Shell EP internal investigation which Shell took very seriously
showed there had been a vigorous and significant response to the safety
review

This Note is my
reply to the Shell statements, and in defense of my integrity and character,
because clearly implicit in the rebuttals is that Campbell is a slightly loopy
guy, who works on perception rather than fact, with the result that he is
defaming the good name of Royal Dutch Shell.

Also to the fact
that I was told that my input to the Shell internal investigation during 2005
was valued, may be rewarded (take that with a pinch of salt) but certainly not
punished. I view the round robin e-mails as punishment through defamation of my
character because they are inaccurate to the point of being deceitful when
compared against the verified facts.

The verified
facts not, allegations, but opinions reached by consensus from their Platform
Management Safety Review in 1999, led by me, and their review into the Technical
Integrity of their 15 offshore installations immediately after the fatal
accident.

And these facts
further supported by HSE documents received by me under the Freedom of
Information Act (FIA) which clarify that the situation from an HSE perspective
was that the conditions in 2003 in the Brent Field had if anything worsened
since 1999 and had further deteriorated by 2005.

It was also the
HSE position, as discussed with David Bainbridge, in October 2003, that if they
had been aware of the conditions prevailing on Brent Bravo in September 1999,
and this is speculation, but still a reasonable probability that they would have
at a minimum issued

·A
notice prohibiting the continued operation of the test separator

·A
notice prohibiting the continued use of firepumps to augment service water via a
full bore connection to the seawater system

·
Improvement notice to make more secure the management arrangements preventing
explosion vents from the columns being impaired

·
And, general improvement notices, change control, maintenance and the setting of
performance criteria for safety equipment, improvements to control room
procedures re the logging and prior approval of inhibits and overrides an on ad
nauseam

·
All this done request the Duty holder to assess the risks as to whether the
installation could continue in full production and otherwise ensure the Duty
Holder informs the safety representatives of its remedial actions to reduce
risks on the installation to the original ALARP levels

One reason that
the HSE were not aware was and I quote Mr. Bainbridge ‘is that their
investigation into workforce concerns in September 1999, i.e. Touch F All et al,
was incompetently handled by the HSE at that time’.

Culpability
rested on the shoulders of the Shell Oil Director who did not revoke statements
made on the 9th September, covered on TV, Radio and in Newspapers
that Touch F All. He described workforce concerns re TFA as not a serious
issue. His conversation is recorded on the BBC Scotland web site, the
interviewer being Colin Wight of the BBC in Aberdeen.

On the morning
of the 5th October and The 22nd October and at the PSMR presentation
on the 22nd October the Oil Director was advised to revoke these
statements but he did not. He was advised that not to do so would be greatly
detrimental to Shell’s reputation, after the fact, as not to revoke the
statements was unethical, immoral and potentially illegal.

Preamble – my prolonged engagement
with Shell on these issues

On the constant
use of the word allegation by Shell I think they will find in due course
that they have been careless in its use. Some of the robust wording in the
rebuttals, one assumes a knee jerk reaction from your crisis team, to get the
boot in first, can not be justified.

But as they say,
attack can sometimes be the best form of defense

An allegation is
an unproven assertion the substance of which is tested for validity in
some arbitration or judicial process.
You need to understand that these
‘allegations’ are significantly based on Shell internal audit and review
reports, output from the Shell prosecution at Stonehaven Sheriff Court, and
confidential papers obtained from the HSE under the Freedom of Information Act.

In forming the
opinion in 1999 as to the condition of controls in Shell Expro, the findings
specifically on Brent Bravo, the recommended actions that should be taken, in
all these, in line with Group audit practice, the outcome was unanimous, and
reached through consensus.

Of the 5 members
of the audit team, 4 were Shell Expro employees and I led the Audit being at
that time an employee of Shell International EP in The Hague.

The Shell
reports mentioned above are the fully owned property of Shell Expro as it was,
so independent persons looking at these note, may think it paradoxical, that a
Company, can call findings in its own internal Audit Report for 1999,
allegations. The Oil Director reluctantly perhaps, but nevertheless accepted
these findings at the time.

The dialogue process to Date

You may not be
aware that these ‘allegations’ as you call them were first copied
in a personal
letter to M Brinded (MB) in December 2004.
He was informed at the time that the
‘allegations’ would come out in a book or article entitled from Cullen to
Chaos. I specifically asked MB if he had any objections to me disclosing these
allegations since it seemed to me that in so doing I was compliant with the
Shell business principles. I received no reply.

I engaged at
that time in dialogue with Shell through Jakob Stausholm (JS) who is the Shell
Group Chief Internal Auditor and later Richard Sykes (RS) who assisted JS and is
the Shell Group Environmental Adviser.

I feel they
handled my concerns with respect and honesty and did the best they could given
that 1999 is a long time away. Also, the self-interested and opposing factions
were still to a degree locked into their original positions, and it must have
been difficult for them to make sense of all this.

In about May
last year I received information in an envelope (about the same time the OIM’s
on Brent Bravo were in the preliminary stages of being disciplined) which was
data on defects and weaknesses in the maintenance and testing of Safety Critical
Equipment (SCE) on 15 offshore installations.

At that time, as
a technical expert, I was able to complete a picture that demonstrated, in at
least my opinion, that there were strong causal linkage between the state of
affairs recorded in a major audit in 1999, and the fatal accident, on 11th
September.

I put this
together in a document called ‘ A Comparative Analysis Brent Bravo 1999 c.f.
2003’. All this was noted on a letter sent through JS to the Chairman and Board
of Royal Dutch Shell in May 2005.

I got no reply
on this from Shell, I also question whether this Note got to the Chairman,
Directors or non-executive Directors, the latter being said to have a more
hands-on role, via the reserves fiasco.

Frustrated at
the time by the slow progress of the investigation I made at least two offers
through JS for myself and perhaps members of the 1999 PSMR team come to
London. I hoped at some blood on the wall session, we could all vent steam,
clear the air and through some deep learning process move forward. And I could
drop the matter. This request was denied.

Finally at a
meeting with the CEO, Legal Counsel, JS and RS in The Hague in July, 2005, we
discussed the investigation findings to date. All this is explained in the
other attachment ‘The evidence the Sheriff did not hear’.

Bottom line was
that I was not satisfied. Although the findings in the main supported in
important issues my position, there were no summary or conclusions, and Shell
would not disclose to me what these were, and what action if any they would be
take against the individuals concerned .

I am sorry to
say, and somewhat ashamed to say, that in their statements that ‘Shell took
these allegations seriously’, my opinion shaped at that time, was the
seriousness related to the risk to their reputation through the exposure of
these issues, rather than determining why we Shell, had allowed the deaths on
Brent Bravo to happen. And what learning’s we could extrapolate from that.

At the end of
the session I informed the CEO that I would put forward evidence to the upcoming
Fatal Accident Inquiry. No objections were raised about this by the Legal
Counsel or the CEO.

The Fatal Accident Inquiry

It’s a long
story, but suffice to say my evidence was not heard at the Inquiry and concerns
about the way the evidence was handled and assessed are under investigation by
the Solicitor General of Scotland. You should also be aware so also are the
allegations made in the attached document ‘The evidence the Sheriff did not
hear’. If you have any issues re this I am sure you can take these up directly
with her.

Whatever action
Shell take, my main concern was to get this evidence heard so that improvements
to the safety regime can be made. And this is still my wish, and I would
welcome the continued support of the media to achieve this.

In my letter to
the Procurator Fiscal in November 2005, there was a conciliatory tone, it just
described the history of PSMR, the comparative analysis etc and 50% of the
letter was looking ahead with proposals that I thought could, with little
effort, improve the current safety regime. The letter was an attempt to get my
evidence into the FAI that I thought would help a critique of the safety regime
if the evidence would be led before the Sheriff.

Has my approaches to Shell been reasonable or dogmatic?

In Scottish law
there is based the concept of reasonableness. As the accuser if you
like, I have demonstrated openness in my dealings with Shell.

At no time since
December 2004 has Shell ever refuted, or challenged these allegations directly
to me. A Sheriff, Judge or Magistrate I would suggest, consider it
unreasonable, for Shell not to have formally challenged these allegations if
they are as you now say completely unjustified and that you now, in June 2006,
for the first time strongly refute these allegations.

He indeed I
suggest would also consider it unreasonable, when given the chance for Directors
to hear these allegations at first hand, that these opportunities were ignored
by the said Directors.

Now in the
further application of this Logic, even the dullest QC from the class of ’86
could, in a summing up say that, the reason Shell did not take up the offer of
my client to better understand these allegations, was that in they already knew
the allegations to be true. And also to support this the QC would extrapolate,
why did Shell, given that these allegations are they claim quasi-defamatory, not
appear on the Frontline Scotland programme, and why also, did the HSE, as a
public authority, not also take up the offer. The Scottish people aren’t thick,
they know why.

Even now
Chairman, the Producer of the programme ‘The Human Price of Oil’ could arrange
an interview with Mr. Paxman, for Mr. Brinded or Mr. Van der Veer to explain why
these allegations are the strings and arrows of their outrageous shareholder and
ex employee.

The Shell internal investigation

As discussed and
shown to me by JS and RB in July the investigation findings listed were that

·
The investigation found no evidence that the short term measures in 1999
recommended to immediately reduce risk on Brent Bravo were ever carried out and
the long term actions to reverse the negative safety culture were truncated when
only 20% complete

·I
understood that in general the members of the PSMR team interviewed were
supportive of me and corroborated in great measure what I alleged,
and, like me
had this abiding sense of failure, abject failure, that our attempt in 1999 to
get Directors of Shell to accept the validity of their own internal audit
findings – we fought against a hostile environment of extreme denial, it was a
surreal experience

·
That the Oil Director Chris Finlayson (CF) has never answered the charge of why
he did not revoke his misleading remarks to media re Touch F All and it appears
he only reluctantly accepted the findings in 1999 ‘to prevent a bun fight
between Auditors and the Brent team’ - nevertheless he accepted the findings
and in the acceptance was obliged to follow then through

·
That the decision of MB to keep the Brent Asset Manager in position was
described by RS as ‘inexplicable’, no explanation was given why he did not
consider the position of the General Manager, and Deputy Asset Manager

·
That Peter Wyatt (PW), at that time HSE Manager in Shell Expro could not
remember in 2005 the contents and discussion of a prolonged meeting at which he
arbitrated between the audit team and the Brent General Manager in 1999 at which
amongst other things it was admitted that ESDV leak-off tests had been purposely
falsified. RS stated he was ‘disappointed’ by PW

·
That MB’s decision to dismiss the SIEP Lead Auditor was because the Brent
Management team would not be perceptive to his continued involvement in remedial
actions – not surprising when the Audit Leader had requested their suspension
from duty

·
That the General Manager of Brent refused to attend the 22nd October
meeting although he knew most of the flak was coming his way. Despite my plea
to the Oil Director to postpone the meeting, in line with Shell Group audit
principles (that is not to discuss the findings of an audit without the auditee
being present), the meeting went ahead

·
That almost no files were now available in UEFA (Internal Audit) department in
Aberdeen related to PSMR, they had gone missing

·
That the PSMR files held by EPS-HE library in the Hague had to be replaced in
2003 by me, they had also gone missing

·
That contrary to recent Shell press statements, no audit was carried out on
Brent Bravo in 2000, but on Brent Charlie

This I think
puts an entirely different reflection on things and suggests that Shell press
releases, indicating that their internal investigation exonerated them, and that
Campbell’s accusations were perception, rather than fact, have been misleading
to the point of deception.

A number of
very serious allegations against Shell in its operations of the Brent Field
and some very personal and completely unjustified attack on current and
former members of staff. Shell strongly refutes these allegations

Shell PA Global Press Release

The allegations
about staff including Directors are covered to a degree in ‘the Evidence the
Sheriff did not hear’. It is difficult for me to understand how Shell can
refute these allegations since they were based on structured interviews with at
all times a minimum of two internal auditors present.

The interviews
with the GM, AM and Deputy AM had three independent auditors present. The
interview with the GM and Deputy AM, where the latter agreed that ESDV tests had
been falsified, and many other deficiencies, was attended by two independent
auditors and the HSE manager.

Audit Notes were
held on these interviews, but they have gone missing. Substantial documentation
was filed supporting the interviews e.g. logbooks, maintenance records,
statements by inspectors etc, but these also have gone missing.

However, in any
court hearing, the auditors could be called to give testimony and the Lord
Advocate, can instruct a Procurator Fiscal, in the case of a Fatal Accident in
Scotland, to seize documentation from a Duty Holder.

The matter could
be better resolved if Shell could indicate to me what allegations against the
conduct of officials it considers unjustified, this also would seem
reasonable request after the fact.

But so that we
are clear on this, the main allegation I make, put already to the Solicitor
General, is that the Asset Manager, the General Manager, the Oil Director and
the Managing Director in 1999, through their inaction to reduce risks on Brent
Bravo, and failure to revoke misleading statements made to the workforce and the
enforcing authority, contributed in some part to the unlawful killing of two
persons on Brent Bravo in September 2003, in that the installation continued to
operate from the 3rd of September till I left on the 22nd
October with no action being taken to reduce risks on the installation.
Further there is no evidence available that any action was ever taken to reduce
risks and the negative safety culture persisted, and was sustained, because
actions to redress bad behavior were also not closed out properly.

I would welcome
any opportunity to give testimony to that allegation in a court of Law.

You should also
be aware that the Procurator Fiscal Depute in Aberdeen, singularly responsible
for the investigation of sudden deaths offshore in Scotland, at the behest of
the HSE reviewed the evidence from the PSMR, and the comparative analysis, in
May 2005.

He concluded,
not that the evidence was invalid, but that it would be difficult to
pursue these allegations given the passage of time. He and the HSE have since
indicated on more than one occasion that they took the evidence presented to
them very seriously.

The
allegations regarding operating with high-risk levels is untrue, and we
absolutely refute this. Safety is our first priority

The recent
Shell EP internal investigation which Shell took very seriously showed there
had been a vigorous and significant response to the safety review

Shell PA Global Press Release

Your Press
Releases continue to mislead your employees and Society as a whole. I do not
dispute that there may have been a vigorous and significant
management response to the safety review. It is not the vigor of the response
that I challenge, but the effectiveness of the response.
When in dire
straights, and when in danger, when in doubt, run in circles scream and shout,
is in my opinion not an effective response.

If
the response to the situation had been effective, the improvements from 1999,
both hardware related and behavioral, should now be reflected in the pristine
condition of your installations, certainly by 4 years later in 2003.

What were the conditions in 2003

As an
example on Brent A, Brent D, Brent C and Brent Delta in the weeks following the
major accident event it was observed by the Shell Technical Integrity Review
team, set up by Greg Hill, the Production Director that
there were

·97
temp repairs on pipework of which 40 of which were not approved

·
56 gas detectors, 26 toxic gas detectors, 9 oil mist detectors, 5 flame
detectors, 1 smoke detector, and 1 General Platform Alarm point that failed to
danger, that is, may not have operated on demand in the event of a major release
of hydrocarbons. And many detectors were observed to be inhibited for long
periods

·A
number of ESDV's had their leak-off test results falsified which may be a
criminal offence and which coincidentally was exactly the same finding as in
1999

I am sorry to
inform you that this litany of deficiencies was common on all 15 Shell Europe
installations, all 15!

Against all this
is the Shell continuing statements in the press releases and to their employees
concerning my involvement in this whole affair that

‘safety is our
foremost priority at all times and we absolutely reject suggestions that we
would ever compromise safety offshore’

But, on the
basis of the data above, are these not empty words!

How can a
Company with Shell's reputation, its published ethics and world class Statement
of General Business Principles issue such a statement against the bare facts as
documented above, its your data, from your people.

And it gets
worse, as previously mentioned, the HSE as enforcing authority in their own
internal Notes state that the conditions on Brent facilities have deteriorated
from 1999 to 2003, and were if anything worse in 2005. Note that this being two
years after the fatalities.

The
allegations regarding operating with high risk levels is untrue, and we
absolutely refute this.

What is the
implication of all above in relation to the Offshore Installation Safety Case
Regulations

·In
summary, Regulation 10 places a duty on a Duty Holder to insure offshore
installations are operated in compliance with their Safety Case at all times, it
is a criminal offence not to do so

·In
summary, Regulation 8 makes it an offence for a Duty Holder not to comply with
the SMS as described in the Safety Case and to ensure all hazards have
been identified as they arise, and the risks from these hazards have been
evaluated. And that such risks are demonstrated to be at the lowest level that
is reasonably practicable - or ALARP

Well I think any
rational person will agree that the examples listed above do not appear to
comply with the requirements of the Safety Case

And, how do you
assess the risks of operating an installation with say 120 people on board,
producing hydrocarbons a high pressure when there are

·32
repairs on hydrocarbon pipework of which 15 not approved, and 56 gas detectors,
150 flame detectors, 36 smoke detectors, 92 General Platform alarms failed to
danger and detectors were observed to be inhibited for long periods and there
was inappropriate testing of ESD valves, and in addition ‘violation of the
permit to work system is common, operators are conditioned to accept the
unacceptable and not ‘Flag’ concerns they have’. Shell Expro’s words, not mine

The simple
answer is you can’t.

Such analysis is
outwith the conventional use of quantitative or even qualitative risk analysis.
So how can Shell ‘strongly refute that the risks in its operationwere
not dangerously high’. The bottom line is they can’t.

But here is the
rub.

In the
post Cullen legislative regime it is the Duty Holder who must demonstrate what
the risks are, not any other person. So what were the risks on the 15
installations in November 2003? How many of them were shut down or had
production or activities curtailed until the Duty Holder carried out immediate
remedial actions to demonstrate that the SCE equipment would actually function
on demand?

The answer to
that is none, but perhaps the Chairman can confirm.

When did Shell
tell their workforce of these heightened risks and when did they share with them
the remedial actions with timescale to complete?

And when did
Shell place the Review findings on the installation in question and discuss
these with the Safety Representatives?

These are all
pertinent questions that the media on behalf of Society have a right to ask,
because if these questions cannot be answered, and that you failed at the
time to assess the risks to your employees on the 15 installations, and take
immediate action to reduce those risks, then you broke the Law.

If Shell can
provide evidence in their rebuttal to the media on this note, namely that in
1999

1.Actions were taken to reduce risks on BB in Oct. 1999 with derails of
job cards, work instructions, 14 day plans, daily reports to support that the
test separator and the fire-main were restored to good working order

2.Actions were take to redress the many other issues

3.Risks were assessed to allow continued operation, after all your audit
team stated these risks were likely to be intolerable, not acceptable to society

4.And that you consulted your workforce on the risk levels, remedial
action plans, and supplied them with a copy of the PSMR findings related to
their platform

5.And you can supply an internal audit report on BB dated 2000 showing
as you say significant improvement

2003

6.And that in 2003 you can produce under para (3) and (4) similar data
for the 15 offshore installations

Then I will
walk away from this, forever and a day after humbly apologising to the Chairman
and Board, and signing up to any Press Release they may wish to send out in my
name.

You don’t need
to show me the material, just box it up and present it to any reporter that
inquires either in Aberdeen or London

Note it all
should be available, so it should be able to be presented in say 48 hours, if
not my friends from the 4th Estate, you can report that it doesn’t
exist

Mr. Geoffrey
Podger has already been asked the questions some months ago about the HSE
reaction to the 15-installation situation in 2003, he is the CEO of the HSE in
the UK, and I still await an answer. He is copied on this Note.

NB

Could I take a moment to thank him, at least he took the allegations seriously,
and complied with the Law in disclosing information to me.

Compare all the
above to the comments by Tom Botts last year ref Online Times et al that ‘Shell
Europe facilities had been subject to a intensive review by the HSE and given
clean bill of health’ or words to that effect. It will not be until Shell
expends the 800m GBP + it is currently planning to correct the degradation that
these facilities will again run with residual risks at ALARP.

Directors should
be more careful in their public announcements. They have a duty not to
misinform the public, or give them false assurances.

A troublesome culture of blame and fear - the case of Mr.
A, B and C

Things were
going wrong offshore in 1998 and 1999, gas release on Cormorant Alpha, problems
on North Cormorant, leakage of radioactive scale on pipework in bound from Brent
Bravo. The PSMR was implemented to ascertain if these incidents were
statistical anomalies or was there systemic weakness in the way safety was being
managed?

The audit
findings in summary was that there were

·
systemic weaknesses in essential controls

·
bad behavior was sustaining a negative safety culture

·
the drivers, the causes of the negative safety culture permeated from Managers
and Directors who demonstrated by their actions a lack of leadership and
commitment to health and safety.

Auditors
witnessed in particular an unhealthy culture of blame and fear both offshore,
and more so in Seafield House where the Brent field was being managed.

The immediate
reaction to the problems was for Asset Managers to discipline the technicians
and supervisors involved, irrespective of their culpability.

Mr. A

For example, the
1999 PSMR review highlighted unsafe disciplinary actions on a technician on
Cormorant Alpha (after the gas release). He had been disciplined following an
early and hurried investigation. This investigation was then discarded and
replaced by another investigation, which led in turn to the disciplining of the
OIM. The same OIM had been party to the earlier disciplining of the
technician. The Audit team asked Shell to revisit this, but this plea was
ignored

Mr. B

As part of the
General Managers (GM) drive to reduce numbers the Brent Management team decided
to half the numbers of Permit Coordinators and Safety Officers in the Brent
field.

These were two
different jobs, with two different competence requirements. So the plan
entailed a force fitting of single competence staff into a two-competence job.
This was achieved by combining the roles so that Mr. B who was a competent
Permit co-ordinator became a combined Permit Coordinator and Safety Officer. The
fact that he was a not yet competent Safety Officer did not seem important.
They would learn on the job. Both these jobs in the Safety Case SMS were listed
as being safety critical.

Mr. B now in the
combined role, working 17 hours a day (all this recorded on timesheets) screwed
up with the radioactive scale tubing causing Shell Expro to be fined lots and
lots of money. He had to be punished and he was. Despite the pleas from the
OIM’s the Asset Manager proceeded with disciplinary action.

When challenged
by the auditors and requested to revoke this action he, the AM, simply stated
that he could not do that because he would be seen to lose face with his people
offshore.

Perhaps this is
an example of what Shell means by ‘some very personal and completely unjustified
attacks’. It certainly is an attack on the ethics and morality, nay Christian
values of the AM, but I would countenance it is not unjustified.

Mr. C

Mr. C was an
independent inspector working for DnV and allocated to the Brents.

His testimony
was that he was coerced and bullied by the AM and his Deputy to sign off in
advance of the work being done. Subsequently, in one example, he signed as in
good working order, all the oil-mist detectors on Brent D. When he eventually
got to Brent D a year later, the oil mist detectors were still unserviceable and
isolated.

In legal
proceedings Mr. A, Mr. B and Mr. C could be called to give testimony to these
facts.

At the same time
as the lower orders were being punished and bullied, the Directors were also
breaking the rules, but that was OK I assume, because lets face, it if a
Director can’t break his own rules who can.

We interviewed
Gerbrand Moyes the then Internal Audit Manager. He showed the auditors extracts
from his Shell Expro 1998 Internal Audit Services Annual Report. In the finance
and commercial section it was noted that a decision agreed and supported by the
Financial Director (FD), and the MD, was taken not to report '‘significant
defalcations’’.

The assurance
letter duly signed off as accurate was returned to The Hague, making no mention
of the defalcation. Or so Mr. Moyes said in his interview witnessed by 4
auditors.

Now Mr. A, and
Mr. B did not in the audit teams opinion break any rules, but they were still
punished. The FD and the MD did break the rules, but they go unpunished.

And we see this
again with the deceased. Early press releases indicate Shell think that the
guys were culpable in some part for their own deaths. Shell Counsel at the FAI
returned to this theme towards the end of the FAI. And of course we have the
statement of the CEO on 25th July 2005, that whatever the
circumstance in 1999 and whatever the relationship with the events of 2003
‘Directors don’t sign permits’.

But as in the
case of Mr. A and Mr. B is it not morally deficient to blame employees
for making mistakes when they work in an environment where non-compliance is
normalized behavior?

And where
essential management controls have broken down? Perhaps the readers should
reflect on all of this when considering a sample of the published Shell business
principles

Shell
companies have at their core values honesty, integrity and respect forpeople

To
employees: To respect the human rights of employees, and to provide
employees with good and safe conditions of work.

@ Royal Dutch Shell Group of Companies

In Conclusion

Shell are a
wonderful Company in my book. Only two times was I ashamed of my Company and
one of these was the PSMR debacle. Otherwise it was a was a pleasure to give
them 24 years of my life.

All that is
written here is about 5 employees.

Strip away the
grand titles and the lofty positions some have achieved, they are still
employees, just like Mr. and Mr. B. The Chairman and Board of Directors have a
commitment to all their employees, and not as in a novel by Orwell, to treat
some as more equal than others.

It seems for
some of the employees of Royal Dutch Shell that the business principles that we
all in Shell aspired to, and which gave us great pride, were to some employees,
just presentational, just propaganda.

My sin, for
which I give no apology, is that I believed in these principles, it’s what made
Shell stand out, but being naďve, has always been my weakness.

Its up to the
media to pursue these matters if it has the inclination or energy, I hope it
has. After all this is not about reserves and the fact that a few fat cat
investors have lost a dollar or two. To make my point, what happened to the
Deputy Asset Manager who accepted he falsified those ESD tests. Well he stayed
on, and was never suspended from duty, only a year or so later, to be sacked for
fraud or embezzlement.

Shell says,
safety is its highest priority, but as is said, actions speak louder than words.

This is about
people, who died needlessly.

ln the same way
as my hero Edward R. Murrow did, and the Washington Post did, when only were
armed only with the truth, I hope the media can give this the energy it deserves
and assist me in getting this incompetent offshore safety regime improved

Hope springs
eternal that the truth will win out in the end, it always seems to.

W.M Campbell -
B.Sc. MIEE C, Eng.

In 1999, SIEP Lead Auditor for PSMR review

Published by Royal
Dutch Shell Plc .com: 8 July 2006

ENDS

(Please note that all of the blue highlighting above is by ShellNews.net - not
by Mr. Campbell)